Escaped Assessment in Different Years Cannot Be Consolidated to Meet Threshold Limit u/s 149 of Income Tax Act: Delhi HC

Delhi High Court held that escaped assessments pertaining to different assessment years cannot be consolidated to meet the threshold limit specified under Section 149 of the Income Tax Act for initiating reassessment proceedings. Section 149 sets a monetary threshold for income that has allegedly escaped assessment, which triggers the tax authorities' power to reopen past assessments. The court's ruling clarifies that this threshold must be met for each individual assessment year and cannot be aggregated across multiple years to justify reassessment. This provides a safeguard for taxpayers against arbitrary reopening of old tax cases.